The actions taken in the initial minutes of an emergency are critical.
The Emergency Action Plan (EAP) or Emergency Response Plan (ERP) is an “action plan” to organize employer and employee actions during workplace emergencies.
Well developed emergency plans and proper employee training will result in fewer injuries and less structural damage to the facility during emergencies. On the other hand, a poorly prepared plan may lead to a disorganized evacuation or emergency response, resulting in confusion, injury, and property damage.
Almost every business is required by OSHA to have an emergency action plan (EAP). OSHA may require you to have an EAP if:
- fire extinguishers are required or provided in your workplace, and
- anyone will be evacuating during a fire or other emergency.
The only exemption to this is if you have an in-house fire brigade in which every employee is trained and equipped to fight fires, and consequently, no one evacuates.
In most circumstances, immediate evacuation is the best policy, especially if professional firefighting services are available to respond quickly. There may be situations where employee firefighting is warranted to give other workers time to escape, or to prevent danger to others by spread of a fire. In this case, the employer is still required to have an EAP.
Minimum Requirements of an Emergency Action Plan(EAP)
Producing a thorough emergency action plan that addresses factors specific to your worksite is straightforward. The first step when developing an emergency response plan is to conduct a risk assessment to identify potential emergency scenarios.
An understanding of what can happen will enable you to determine resource requirements and to develop plans and procedures to prepare your business.
Emergency Response Plan includes using what was identified and learned from the risk assessment and describing the way employees should respond to various kinds of emergencies, taking into consideration your unique worksite layout, structural features, and emergency systems.
The commitment and support of all employees is essential to the plan’s success in case of an emergency; request their assistance in creating and employing your emergency action plan. For smaller organizations, the plan does not need to be written and may be communicated orally if there are 10 or fewer employees. [29 CFR 1910.38(b)]
Evaluating Your Workplace
The best way to protect yourself and others is to prepare for an emergency before it happens by doing a thorough assessment of the workplace. Think about possible emergency situations and evaluate your workplace to see if it is sufficiently prepared using the following OSHA standards:
- Design and construction requirements for exit routes– 29 CFR 1910.36. This standard contains requirements for the design and construction of exit routes. It includes a requirement that exit routes be permanent, addresses fire resistance-ratings of construction materials used in exit stairways (exits), describes openings into exits, defines the minimum number of exit routes in workplaces, addresses exit discharges, and discusses locked exit route doors, and exit route doors. It also addresses the capacity, height and width of exit routes, and finally, it sets forth requirements for exit routes that are outside a building.
- Maintenance, safeguards, and operational features for exit routes – 29 CFR 1910.37. This standard includes requirements for the safe use of exit routes during an emergency, lighting and marking exit routes, fire retardant paints, exit routes during construction, repairs, or alterations, and employee alarm systems.
Learn more about Emergency Exits
- Emergency action plans (EAP) – 29 CFR 1910.38. Again, the EAP facilitates and organizes employer and employee actions during workplace emergencies.
- Fire prevention plans (FPP) – 29 CFR 1910.39. The purpose of the fire prevention plan is to prevent a fire from occurring in a workplace. It describes the fuel sources (hazardous or other materials) on site that could initiate or contribute both to the spread of a fire, as well as the building systems, such as fixed fire extinguishing systems and alarm systems, in place to control the ignition or spread of a fire.
Learn more about Fire Prevention Plans
- Portable fire extinguishers – 29 CFR 1910.157. Workplace fires and explosions kill hundreds and injure thousands of workers each year. One way to limit the amount of damage due to such fires is to make portable fire extinguishers an important part of your fire prevention program. When used properly, fire extinguishers can save lives and property by putting out a small fire or controlling a fire until additional help arrives.
Learn more about OSHA standards for Fire Extinguishers
- Fixed extinguishing systems – 29 CFR 1910.160. Fixed fire extinguishing/suppression systems are commonly used to protect areas containing valuable or critical equipment such as data processing rooms, telecommunication switches, and process control rooms. Its main function is to quickly extinguish a developing fire and alert occupants before extensive damage occurs by filling the protected area with a gas or chemical extinguishing agent.
- Fire detection systems – 29 CFR 1910.164. Automatic fire detection systems, when combined with other elements of an emergency response and evacuation plan, can significantly reduce property damage, personal injuries, and loss of life from fire in the workplace. Its main function is to quickly identify a developing fire and alert building occupants and emergency response personnel before extensive damage occurs. Automatic fire detection systems do this by using electronic sensors to detect the smoke, heat, or flames from a fire and providing an early warning.
- Employee alarm systems – 29 CFR 1910.165. The purpose of the employee alarm systems standard is to reduce the severity of workplace accidents and injuries by ensuring that alarm systems operate properly and procedures are in place to alert employees to workplace emergencies.
Learn more about Sheltering in place
How to Develop an Emergency Response Plan
Knowing the OSHA regulations, and best practices for emergency response, is the best way to build an ERP. Below I list out the different components you should consider when developing an emergency response plan:
Elements the Emergency Response Plan Must Include
but is not limited to the following elements [29 CFR 1910.38(c)]:
- Means of reporting fires and other emergencies: Procedures for reporting a fire or other emergency. There are preferred procedures for reporting emergencies such as dialing 911, or an internal emergency number, or pulling a manual fire alarm but there are many other possibilities. [29 CFR 1910.38(c)(1)]
- Evacuation procedures and emergency escape route assignments: Evacuation policies, procedures, and escape route assignments are put into place so that employees understand who is authorized to order an evacuation, under what conditions an evacuation would be necessary, how to evacuate, and what routes to take. Exit diagrams are typically used to identify the escape routes to be followed by employees from each specific facility location. [29 CFR 1910.38(c)(2)]
- Procedures for employees who remain to operate critical plant operations before they evacuate: Employees may be required to operate fire extinguishers or shut down gas and/or electrical systems and other special equipment that could be damaged if left operating or create additional hazards to emergency responders (such as releasing hazardous materials). [29 CFR 1910.38(c)(3)]
- Accounting for all employees after an emergency evacuation has been completed: Procedures to account for employees after the evacuation to ensure that everyone got out may include designating employees to sweep areas, checking offices and rest rooms before being the last to leave a workplace or conducting a roll call in the assembly area. Many employers designate an “evacuation warden” to assist others in an evacuation and to account for personnel. [29 CFR 1910.38(c)(4)]
- Rescue and Medical Duties for Employees Performing Them: Most small organizations rely on local public resources such as the local fire department or hospital to provide these services. [29 CFR 1910.38(c)(5)]
- Names or job titles of persons who can be contacted: Names, titles, departments, and telephone numbers of employees who can be contacted for additional information and/or explanation of their duties under the plan. [29 CFR 1910.38(c)(6)]
When writing an emergency response plan these additional elements may be helpful to consider:
- A description of the alarm system to be used to notify employees (including disabled employees) to evacuate and/or take other actions. The alarms used for different actions should be distinctive and might include horn blasts, sirens, or even public address systems.
- The site of an alternative communications center to be used in the event of a fire or explosion.
- A secure on- or offsite location to store originals or duplicate copies of accounting records, legal documents, your employees’ emergency contact lists, and other essential records.
Check out: Emergency Response Plan Checklist
How and When to Train Employees on Emergency Action Plan Components
Training should be offered employees when you develop your initial plan and when new employees are hired. Employees should be trained or retrained as required when your plan changes due to a change in the layout or design of the facility, when new equipment, hazardous materials, or processes are introduced that affect evacuation routes, or when new types of hazards are introduced that require special actions.
General training for your employees should address the following:
- Individual roles and responsibilities;
- Threats, hazards, and protective actions;
- Notification, warning, and communications procedures;
- Emergency response procedures;
- Evacuation, shelter, and accountability procedures;
- Location and use of common emergency equipment; and
- Emergency shutdown procedures.
You may also need to provide additional training to your employees (i.e. first-aid procedures, portable fire extinguisher use, etc.) depending on the responsibilities allocated to employees in your plan.
Conducting Drills and Retraining
If training is not reinforced, it will be forgotten. Consider retraining employees annually.
Once you have reviewed your emergency action plan with your employees and everyone has had the proper training, it is a good idea to hold practice drills as often as necessary to keep employees prepared. Include outside resources such as fire and police departments when possible. After each drill, gather management and employees to evaluate the effectiveness of the drill. Identify the strengths and weaknesses of your plan and work to improve it.